​Question:We have a customer who is considering borrowing money for home improvements but wants to use cattle as the collateral to the loan. What disclosures would need to be done if there is no real property involved?

Answer: Only Truth in Lending disclosures are required, similar to a consumer loan. TRID disclosures are not required, because even though the loan is for consumer-related home improvement, it is not secured by a dwelling. Note, however, that since it is a home improvement loan, it will be subject to HMDA and you will be required to obtain the government monitoring information (if you are a HMDA bank).